Connecticut Department of 

ENERGY & 

~ ENVIRONMENTAL 

~ PROTECTION 

79 Elm Street " Hartford, CT 06106-5127 www.ct.gov/deep Affirmative Action/Equal Opportunity Employer 

June 15, 2012 

David Conroy, Chief, Air Programs Branch 

U.S . Environmental Protection Agency, Region 1 

5 Post Office Square- Suite 100 (Mail Code OEP05-2) 

Boston, MA 02109-3912 

Re: Update to Connecticut PM2.5 Infrastructure Submittals 

Dear Mr. Conroy: 

The Connecticut Department of Energy and Environmental Protection (DEEP) has submitted 

State Implementation Plan (SIP) revisions addressing the adequacy of DEEP's SIP with respect 

to section 110(a)(1) and (2) of the Clean Air Act (CAA) for the 1997 and 2006 fine particulate 

matter (PM2.5) national ambient air quality standards (NAAQS). At your request, DEEP is 

submitting this letter to provide the current status of certain regulatory revisions necessary to 

satisfy the infrastructure elements and to provide you with new information concerning one of 

the infrastructure elements. 

DEEP is currently seeking the revision of its prevention of significant deterioration (PSD) permit 

program to add increments, significant emission rate thresholds, and significant impact levels for 

PMZ.5 consistent with the U.S . Environmental Protection Agency's (EPA's) implementation 

rules. The regulatory revision process is moving forward; the committee of the Connecticut 

General Assembly responsible for regulatory review is scheduled to review the PSD program 

revisions on June 26, 2012 . If the proposal is approved by the committee, DEEP expects to 

complete the adoption process by mid-July. Once the proposed revisions are effective in 

Connecticut, DEEP will submit them immediately to EPA. 

With respect to procedural steps necessary to formalize DEEP's current practice of making all 

required notifications pursuant to CAA Section 126 and the PSD program requirements of 40 

Code of Federal Regulations (CFR) section 51 .166(q), DEEP proposed such revisions to its 

permit program notification requirements on January 31, 2012. This proposal will make the 

requirements of section 22a-174-2a(b)(5) and (6) of the Regulations of Connecticut State 

Agencies consistent with CAA section 126, 40 CFR 51 .166(q) and 40 CFR 70 .7(h) and 70.8(b) . 

Having recently received approval from the Office of Attorney General to move forward with the 

proposed revisions, DEEP expects the proposed revisions to be scheduled for review by the 

General Assembly committee in August 2012. If approved by that committee, DEEP would seek 

to complete the revision process by mid-September and would then submit the revisions to EPA 

as quickly as possible . DEEP has no pending obligations under CAA sections 115 or 126. 
David Conroy 

Page 2 

June 15, 2012 

EPA has brought to DEEP's attention the requirement of CAA section 128(a)(2), which requires 

that a SIP contain adequate provisions requiring the DEEP commissioner to disclose any 

potential conflicts of interest . Connecticut has in place conflict of interest provisions that are 

broader than EPA's minimum requirements and that apply to all state employees and public 

officials. Connecticut's requirements, which are set out in section 1-85 of the Connecticut 

General Statutes (CGS), prevent DEEP's commissioner from acting on a matter when a 

substantial conflict of interest exists . CGS section 1-85 is available at the following link : 

http ://www.cg_a.ct.gov/2011/pub/chap010.htm#Secl-85.htm. DEEP intends to submit the statute 

into the SIP prior to September 2013 . The submitted conflict of interest provisions will apply 

not only to the 1997 and 2006 PM2,5 NAAQS but also the 2008 lead NAAQS, for which the 

infrastructure SIP was submitted on October 13, 2011, and the 1997 8-hour ozone NAAQS, for 

which the infrastructure SIP was submitted on December 28, 2007 and approved July 8, 2011 . 

In summary, prior to September 2013, DEEP expects to provide EPA with all the outstanding 

elements necessary to satisfy Connecticut's infrastructure requirements for the PM2,5 NAAQS. I 

hope this additional information allows EPA to move forward with the process of approving 

Connecticut's PM2,5 NAAQS infrastructure SIP submissions. Please contact me you need any 

additional information. 

Sincerely, 

Anne R. Gobin, Chief 

Bureau of Air Management 

cc: Alison Simcox, EPA Region 1